Other comments

Scope of the review

The focus of the discussion document was to identify issues in the Building Code regulations and other related regulations, including:

• the fire safety provisions set out in the objectives, functional requirements, and performance criteria in the Building Code
• other regulations under the Building Act that are consequentially impacted.

The discussion document did not make any specific proposals to change the Building Act, the regulations, acceptable solutions, or verification methods. However, submitters were able to provide further feedback to MBIE at the end of the survey on any other aspects of fire safety and the building regulatory system.

Questions on the outcomes

These questions provided opportunities for comments on other aspects of fire safety. 

15. If you have any other comments on this review, please tell us.

16. If you have anything else you would like to tell MBIE about fire safety in the Building Code, please leave your feedback below.

Response to questions

42 individual comments from 28 submitters in response to these two questions were determined to be in scope of the review. The remaining comments are discussed in section 8.3 below.

8 submitters provided general support for the review and four encouraged further consultation as the review progresses. A further 10 comments related to specific matters covered elsewhere, which have been incorporated into the analysis in the preceding sections. The remaining comments were about:

• specific acceptable solutions or verification methods (7)
• ensuring changes lead to simple, clear and consistent requirements, and gaps are minimised (5)
• specific code clauses (5)
• support for visual alerting devices (2).

Out of scope comments

Across all responses to all questions, there were 160 out of scope comments. The most common comments were about the regulation or competency of those involved in the design and consent process or the building consent system itself. Table 8.1 shows the number of comments by summary topic.

Table 8.1: Number of out of scope comments by topic

Some of the comments made by multiple submitters included:

• section 112 (Alteration of existing buildings) of the Building Act should be amended due to challenges such as the application of the ‘as near as reasonably practicable’ requirement
• some or all products should be subject to third-party certification
• roles and responsibilities are unclear
• competency needs to be lifted across a range of professions or roles, including designers, engineers, BCAs or territorial authorities, and IQPs
• there are challenges or inconsistencies in relation to the role of FENZ in the consenting process.

< Contributing issues from the background paper | Appendix A: List of submitters >